INTENT

This Policy applies to CROSSMULLER PTY. LIMITED (ACN: 088 327 093) and all of its related bodies corporate and entities from time to time (referred to collectively as “Crossmuller”).

Crossmuller is committed to compliance with privacy laws which apply to its business. This Privacy Policy outlines how we collect, hold, use and disclose personal information, how personal information can be accessed, and complaints lodged in relation to how personal information has been handled.

REFERENCES

• Privacy Act 1988

POLICY

Collection of Personal Information

Crossmuller collects personal information which is reasonably necessary for our business functions and activities. The type of personal information we collect and hold includes:

• Personal information such as names, contact details, employment history, education qualifications, government related identifiers (e.g. tax file numbers, driver licence and passport information), age, gender, and other information people voluntarily provide to Borg.
• Sensitive information such as health information, which may be collected for the purpose of prospective employment.
• Personal information disclosed by customers and stakeholders when establishing an account with Crossmuller or invoicing Crossmuller for products and services, and information disclosed when otherwise communicating with our Accounts departments.
• If you are a supplier or a prospective supplier, information about your business skills, services, products and prices.
• If you are a prospective customer, information about the type of product or service you are interested in acquiring from us.
• Statistical information regarding views, navigation paths, purchasing behaviour, your location when accessing/using the website, your access and use of the website.
• Your computer’s internet protocol address and information that helps us learn about your browser and operating system.
• Complaint details.
• Other information as may be required in order to use the website in the way in which it is intended or which you choose to provide us.

How Personal Information is Collected and Held

Personal information is usually collected directly from the relevant individual. Personal information can be collected when:

• Submitting an application or expression of interest for employment opportunities or work experience.
• Making an enquiry or communicating with Crossmuller via our website, email, fax, phone, post, in person, or using other communication channels.
• Completing an account application.
• Subscribing to an alert, newsletter, or other service.
• Using Crossmuller social media platforms.
• Registering to attend Crossmuller events.
• Completing a form or survey or enter a competition or promotion.

Personal information may also be obtained from third parties such as recruitment agencies, medical service providers, publicly available resources, or through customers and suppliers where enquiries have been made by individuals about Borg products and/or services. In such circumstances we rely on the third party to obtain consent from the individual.

Purpose of Collecting, Holding, Using and Disclosing Personal Information

Personal information is collected in order to conduct business functions and activities, such as:

• Providing products, services and information to customers and other stakeholders, including for the purposes of direct marketing.
• Verification of identity for financial transactions.
• Relating to current and future employment opportunities.
• Provide functionality of the website, monitor or improve the use of and satisfaction with the website and services we provide
• For internal reporting and the management of contracts.
• To learn about your browser and operating system.
• Other reasons as advised to the particular person, or authorised by a particular person when providing the information.

When we no longer need your personal information for the above purposes, we will ensure that the information is destroyed or de-identified.

Personal information may be disclosed in the following circumstances:

• Within the Crossmuller group (for example, to related companies or entities of Crossmuller)
• To third parties for relevant business functions and activities. For example, medical services providers, outsourcing services, couriers/transport companies, financial institutions for the purpose of processing payments, and business support services.
• As required by law.

Security

We hold your information in paper-based and electronic files.

We take reasonable precautions and follow industry best practices to guard against the loss, misuse, inappropriate access, disclosure or alteration of your personal information and in the course of destruction of your personal information. The measures we take include ensuring that electronic data is held in electronic databases with password access and virus and firewall protection procedures, sensitive personal information is only accessible by designated staff bound by duties of confidentiality and physical and logical security measured are implemented to deal with threats (both external and the possibility of internal threats).

Changes to this Privacy Policy

We may modify this Privacy Policy at any time. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it and under what circumstances, if any, we use and/or disclose it.

Accessing and Correcting Personal Information

Personal information can be accessed, amended, or a request made to remove the information by contacting the Privacy Officer by email at privacyofficer@borgs.com.au, or by mail to 2 Wella Way, Somersby NSW 2250. Crossmuller will respond to your request within 30 days of receiving the initial request.

Before we provide access to personal information we may require some proof of identity. We may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part.

Complaints

Complaints in relation to how personal information has been handled, or potential or alleged breaches of the Principles or Privacy Act can be made by contacting the Privacy Officer by email at privacyofficer@borgs.com.au, or by mail to 2 Wella Way, Somersby NSW 2250.

The Privacy Officer will investigate the matter and attempt the resolve the issue, and will inform the complainant in writing about the outcome of the investigation. If the complaint is not resolved to the satisfaction of the complainant, the Privacy Officer will provide contact details of the Office of the Australian Information Commissioner where the complaint may be escalated.

This document was last modified May 2020.